Can a Phase I be eliminated by moving directly to a Phase II assessment?
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Schools-2009 SSp2: Environmental Site Assessment
Can a Phase I be eliminated by moving directly to a Phase II assessment?
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Larry Sims
PrincipalStudio4, LLC
LEEDuser Expert
161 thumbs up
November 20, 2012 - 1:49 pm
Michael, typically no due to the fact they perform different tasks. Phase I reports are more of an investigative process, as opposed to Phase II reports which are typically limited in nature (i.e. contamination testing)and are usually the result of a Recognized Environmental Condition (REC) being found, or suspected, in a Phase I report.
Phase I reports usually include the following:
Inspecting sites to identify potential environmental liabilities, such as, vent or fill pipes to locate USTs, transformers or capacitors to identify potential PCB sources, asbestos containing materials, hazardous chemical storage, and other sources of environmental contamination
Interviewing property owners to determine historical use and activities at the property
Reviewing regulatory environmental files maintained by state and local governments
Reviewing regulatory environmental data bases, such as the National Priority List (NPL), State Hazardous Waste Sites list, and Leaking UST list, to name a few
Reviewing neighboring properties to evaluate the potential for off-site contamination
Researching aerial photographs, soil conservation surveys, city records, environmental liens, and environmental permits
Reviewing other available environmental information and reports
Phase 2 Environmental Assessments consist of collecting and testing samples for contamination found to determine if they are significant to exceed federal, state or local cleanup or human-health risk standards.
Jean Marais
b.i.g. Bechtold DesignBuilder Expert832 thumbs up
November 20, 2012 - 3:05 pm
I'm no EA expert, but that sounds ridiculous. Either the phase II is not worth it's salt or this sounds like a money making racket. Phase I is investigative, almost speculative, where Phase II is hard evidence based on physical sampling (which should be robust) and (should) also be conserned with the stability, i.e. source of the site pollution. Surely phase I was developed to save time and money for not all sites to do this investigation.
Tristan Roberts
RepresentativeVermont House of Representatives
LEEDuser Expert
11478 thumbs up
November 20, 2012 - 3:28 pm
I'm not an expert on this, but it seems to me that if you are going in and testing for contaminants with Phase II, you need to have some idea of what you are looking for, and where—or else you could look in the wrong place, for the wrong thing. Phase I helps define likely issues, and gives Phase II the chance to verify whether issues are present or not.
Jean Marais
b.i.g. Bechtold DesignBuilder Expert832 thumbs up
November 20, 2012 - 3:50 pm
That makes sense. A bit like doing blood work. In that case you should consider Phase I a prerequisite for phase II. We're spoilt here In Germany, where I believe these are lumped...and always required (there are still bombs laying around from the world wars, particularly WWII so it's also a real safety proceedure). They have a massive database called the "Altlastregister" which covers almost all developed land for almost the last 100 years. If there was ever a fuel station there, it would be listed.
Larry Sims
PrincipalStudio4, LLC
LEEDuser Expert
161 thumbs up
November 20, 2012 - 4:17 pm
Important Phase I factors to consider: First, a Phase I ESA is not a LEED requirement, except when the project relates to Schools: hence, SSp2. Second, most lending institutions will require a Phase I for their own protection. Third, a Phase I will indicate the necessity for a Phase II follow-up.
Important Phase II factors to consider: First, the purpose of a Phase II ESA is to evaluate any recognized environmental conditions identified in a Phase I ESA or Transaction Screen to provide sufficient information regarding the nature and extent of contamination. Second, the Phase II ESA is completed to assist in making informed business decisions about the property; and where applicable, to provide the level of knowledge necessary to satisfy the innocent purchaser defense under CERCLA. This is usually accomplished by field sampling and laboratory analyses of air, soil, groundwater, and/or site building materials to assess the presence and extent of identified or suspected hazardous or regulated materials. This testing is recommended when there is a significant potential for the existence of an environmental liability that can affect the value of a property. Environmental liabilities are costs associated with regulatory-mandated cleanup, disposal of regulated-waste and civil liability. Civil liability occurs when the contamination has migrated offsite or tenants sue over exposure to hazardous materials.